In a move that signals a potential paradigm shift for U.S. equity market structure, the Securities and Exchange Commission has unveiled a comprehensive agenda for its upcoming roundtable regarding the future of Regulation NMS. Centering on the contentious trade-through prohibitions of Rule 611, the convening is scheduled for December 16, 2025, at the University of Austin’s Scarbrough Building. This high-level policy forum arrives at a critical juncture for domestic capital markets, as regulators and industry participants grapple with the complexities of liquidity fragmentation and the evolving nature of price discovery in an increasingly high-speed environment.
The proceedings will commence at 9 a.m. CT with opening remarks from a formidable slate of agency leadership, including SEC Chairman Paul Atkins and Commissioners Hester Peirce, Caroline Crenshaw, and Mark Uyeda. Joining them will be Jamie Selway, the Director of the SEC’s Division of Trading and Markets, whose office will play a pivotal role in moderating the day’s discussions. For those attending in person at the Congress Avenue campus, doors will open at 8 a.m. CT, though the Commission has noted that visitors will be subject to standard security protocols and must complete their registration by the December 15 deadline. Recognizing the global interest in these regulatory developments, the SEC will also provide a live webcast of the event through its official website, with a permanent recording to be archived for subsequent analysis.
The morning’s first session will pivot toward the intricate interplay between Rule 611 and Rule 610. As the Commission explores the possibility of modifying or entirely rescinding trade-through protections, the panel will scrutinize the necessary adjustments to fair access provisions and the existing caps on access fees. Under the guidance of Selway and Deputy Director Jon Kroeper, panelists will debate the prohibition on locked and crossed markets, assessing whether the current regulatory architecture remains fit for purpose or if it stifles the very competition it was designed to foster. This technical deep dive is expected to address how the removal of federal price protections might necessitate a reimagining of how market participants interact with various execution venues.
Following a brief mid-morning recess, the focus will shift to the foundational definitions of Rule 600 and the broader implications for market data. This second panel will examine the technical "plumbing" of the markets, specifically looking at how amendments to Rule 611 would ripple through the National Best Bid and Offer (NBBO) calculations. Of particular interest to institutional investors will be the discussion on revenue allocation formulas within consolidated market data plans. The moderators, including Senior Policy Advisor Peggy Sullivan, intend to lead an inquiry into the incentives that currently drive data distribution and whether a shift in Rule 611 would require a total overhaul of how market information is defined and monetized.
The final segment of the day will address the fiduciary heart of the industry: best execution obligations. If the SEC moves away from the prescriptive nature of the trade-through rule, the burden of proof for broker-dealers to demonstrate they have achieved the most favorable terms for their clients will likely increase. This third panel will seek to identify what additional guidance the Commission must provide to ensure that investor protection is not compromised in a post-Rule 611 landscape. By the time the roundtable concludes at 1 p.m. CT, the Commission hopes to have gathered the necessary intellectual capital to chart a course for a more efficient, transparent, and resilient market structure for the coming decade.
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